IN THE COURT OF THE HONBLE SPECIAL EXCISE
MUNSIF MAGISTRATE COURT: ONGOLE
Crl.M.P: of 2024
in
(Crime No. 150/2024 of
II Town Police Station)
Between:
Potluri Chandrashekar,
S/o.Adinarayana,
Age 43 years, R/o.33-163/1,
Ramnagar, Addanki Mandal,
Prakasam District … Petitioner/Accused
AND
1. The State, Station House officer,
II Town Police Station,
Rep. by Special Public Prosecutor, Ongole. ... (Complainant)
AFFIDAVIT FILED ON BEHALF OF THE PETITIONER/
OWNER OF THE VEHICLE BEARING NO.
I, Potluri Chandrashekar,S/o.Adinarayana,Age 43 years, R/o.33-
163/1,Ramnagar, Addanki Mandal, Prakasam District .,do hereby
solemnly affirmed and state on oath as follows
I humbly submitted that I am the petitioner herein and owner of
Vehicle bearing no.AP 39 TQ 0758 , TATA MOTORS LTD., T.16 ULTRA
DCR45HSQ 180B6M6 shown in the above noted crime. It is humbly
submitted that as per alleged special report in FIR bearing no.254 of
2022 prepared by the police that the offence is U/s 420 R/W 34
IPC,21(1)MMDARA 26(1)MMR, Chimakurthy Mandal occurred on 21-
09-2022 at about 07:30 hours in Chimakurthy, Praksam District
-2-
whereas that the complainant is respected citizen and having good
background and running transport business to his livelihood and by
way of doing his own business he is transporting waste granite slabs
to small cutting industries , the accused is no way connected to the
above crime as he is involved in transporting of goods ,dated 21-09-
2022 The S.I Chimakurthy police stopped the vehicle and asked all
the bills as the driver of the vehicle has showed all the bills but with
an ill motive to grab money the police asked for extra money , the
lorry driver who is accused No.1 in the above crime denied to pay the
alleged bribery amount, taking the advantages of the driver illtratecy
taken signatures and seized the above vehicle. The police with a
malafide intention and to dupe the accused the complainant and
Police, has induced the petitioner into this crime in which the accused
has no way related to the above crime and created a fabricated
stories and induced the accused No.1 and 2 intentionally booked a
false case by harassing the accused and framed the alleged charges
in the fir No.254/2022 .,
I humbly submitted that if the vehicle were kept idle, it will go
rust and dead and not useful as I am only bread earner in my family
by only transporting the goods to various places.
I humbly submitted that I am herewith undertaking that I
produce the vehicle when required by this Hon’ble Court. I can also
undertake that I will not change the color and physical features .
Hence I pray that this Hon’ble Court be pleased to return the vehicle
AP 39 TQ 0758 , TATA MOTORS LTD., T.16 ULTRA DCR45HSQ
180B6M6 chassis No. MAT780013LF04344 to me as interim custody
till the conclusion of the case, in the interest of justice.
-3-
Be pleased to consider,
Deponent
Solemnly affirmed and signed before me on this 4 th day of April,
2023 at Ongole.
Advocate, Ongole
Enclosures:
1. copy of Aadhar Card of the petitioner.
2. FIR Copies in crime no.16/2019, crime no.34/2020.
3. R.C of the above vehicle.
IN THE COURT OF THE HONBLE SPECIAL EXCISE
MUNSIF MAGISTRATE COURT: ONGOLE
Crl.M.P: of 2023
in
(Crime No. 254/2022 of
Chimakurthy Police Station)
Between:
Potluri Chandrashekar,
S/o.Adinarayana,
Age 43 years, R/o.33-163/1,
Ramnagar, Addanki Mandal,
Prakasam District … Petitioner/Accused
AND
1. The State, Station House officer,
Chimakurthy Police Station,
Rep. by Special Public Prosecutor, Ongole. ... (Complainant)
PETITION FILED ON BEHALF OF HE PETITIONER/OWNER OF
MOBILE PHONE U/SEC.451 OF CR.P.C
For the reasons stated in the accompanying affidavit, it is
prayed that this Hon’ble Court may be pleased to order for grant of
interim custody of vehicle bearing No. AP 39 TQ 0758 , TATA MOTORS
LTD., T.16 ULTRA DCR45HSQ 180B6M6 chassis No.
MAT780013LF04344 on the facts of above case and handover the
above to the petitioner till the conclusion of the case and pass such
other reliefs in the interest of justice or else the petitioner will be put
into irreparable loss.
Be pleased to consider,
Place: Ongole,
Date: -04-2023. Advocate for petitioner/
Owner of the vehicle
M.S.K
IN THE COURT OF THE
HONBLE SPECIAL
EXCISE MUNSIF
MAGISTRATE COURT:
ONGOLE
Crl.M.P: of 2023
in
(Crime No. 254/2022 of
Chimakurthy Police
Station)
PETITION FILED ON
BEHALF OF HE
PETITIONER/OWNER OF
THE MOBILE U/SEC.451
OF CR.P.C
Filed by : counsel for
complainat/petitione
r
Field on: 12/04/2023
FILED BY;
Mannam Sudheer Kumar,
T.Lakshmi Narayana
M.Ajay Chowdary
High Court Advocates,
Ongole.
Cell No.7842487475
